This privacy notice is for members of pension schemes where the Scheme Actuary is employed by SPM Employee Benefits Limited.

Introduction

SPM Employee Benefits Limited, including the Scheme Actuary, (“referred to as “SPMEB”, “we”, “us” or “our” in this privacy notice”) respects your privacy and is committed to protecting your personal data.

This privacy notice explains the types of personal information the Scheme Actuary collects, how he or she uses that information and whom he or she share it with in order to fulfil the role of Scheme Actuary to your pension scheme, and also sets out how we protect that information.

This version was last updated on 25 May 2018.  We may update this Privacy Policy from time to time, in particular to respond to changing legal, regulatory or operational requirements. We will ask the Trustees of your scheme to notify you of any such changes (including when they will take effect).

  1. The data we collect about you

Personal data, or personal information, means any information about a living individual from which that person can be identified.

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

  • Identity Data includes first name, last name, date of birth, gender, National Insurance number.
  • Scheme Data includes membership identification number, pensionable pay and details of salary, length of service, employment and scheme membership dates, contributions paid, pension entitlement and details of any benefits transferred from another scheme.

We may also hold some Special Categories of, or “sensitive”, personal data about you, for example in relation to ill-health or death benefits.   This will not happen without your consent.

  1. How is your personal data collected?

We obtain your personal data from the scheme Trustees, or from other advisers appointed by the Trustees.

  1. How we use your personal data and the legal basis we rely on

We will use your personal information for one or more of the following reasons:

  • to perform valuations of the liabilities of the scheme,
  • to check or review a calculation of the benefits you are entitled to,
  • to calculate the value of your scheme benefits, either because you have requested a transfer value quotation or because you need a value for divorce purposes.

We do not use your data for profiling or any form of automated decision making.

The legal bases we rely on to process your data are as follows:

  • to comply with a legal or regulatory obligation,
  • for our legitimate interests, so that we can fulfil a contract to provide Scheme Actuary services to the Trustees,
  • for the Trustees’ legitimate interests and
  • your consent, in the case of Special Category data.
  1. Disclosure of your personal data

The Scheme Actuary will share your personal data with other SPMEB employees who are involved in the Scheme Actuary services and your data will be held on SPMEB’s server.  SPMEB acts as a data processor for this purpose.

The Scheme Actuary may also need to share your data with the Trustees, for example for them to make a decision about the benefits that are payable to you, and to their other advisers such as auditors.

If we choose to sell, transfer or merge part or all of our business, the new owners may use your personal data in the same way as set out in this privacy notice.

Any personal information held by us and any third party will be treated as confidential. We will never sell your personal information to any other parties.

  1. International transfers

We will not transfer your personal data outside the European Economic Area (EEA).

  1. Data security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees and other third parties who have a business need to know. They will process your personal data only on the Scheme Actuary’s instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

  1. Data retention

We will retain your personal data only for as long as necessary to fulfil the purposes we collected it for.  Generally this will mean as long as we provide services to the Trustees.  We may, however, retain your personal data for a further period of time to enable us to comply with regulatory obligations and to defend legal claims.

When we no longer need to use your information, we will remove it from our systems and records and/or take steps to anonymise it so that you can no longer be identified from it.

  1. Your legal rights

Under certain circumstances, you have the following rights under data protection laws in relation to your personal data:

  • Request access to your personal data (commonly known as a “data subject access request”).
  • Request correction of the personal data that we hold about you.
  • Request erasure of your personal data.
  • Object to processing of your personal data in particular circumstances.
  • Request restriction of processing of your personal data.
  • Request the transfer of your personal data to you or to a third party.

If you wish to exercise any of the rights set out above, please contact the Trustees of your scheme in the first instance.

You also have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO, so please contact us or the Trustees in the first instance.

  1. Our contact details

If you have any questions about your privacy in relation to the scheme, please contact the Trustees.  You will find their contact details on the latest Summary Funding Statement.  If you would like to contact SPMEB or the Scheme Actuary directly please contact SPMEB’s data privacy manager initially, using the details set out below.

Lauren Owen
Data Protection Manager
SPM Employee Benefits Limited

l.owen@sterlingpensions.co.uk

City Reach
5 Greenwich View Place
Millharbour
London
E14 9NN